Maybe a short statement ahead: I don't think Ringheroes should be "balanced" in the conventional way (because they normally are only enabled for fun).
Of course they shouldn't be an immediate win, but currently most of them aren't much stronger than their standard versions, especially at lower Levels.
While I do think Sauron needs some changes, this feels more like a debuff to me.
Unless Sauron was substantially buffed in 4.5; weakening him would make him basically completely unable to compete with Gorthaur and his different forms in my opinion.
I personally think that the passive ability is a cool idea, but I would rather have it instead of "Consuming Darkness"; an ability which I never really liked and that is not at all supported by Lore.
This could then lead to Dark Will losing the "trample" damage, but still being a factor in showing that Sauron is by far the strongest being in the Third Age(even without Ring, he is stronger than Galadriel or Elrond with Ring); and should he get his most powerful weapon back, the fall of middle-earth could not be stopped (which is the entire point of Lotr :D).
I would be totally fine with Sauron being a mass-slayer rather than the OP supporter/negative supporter (and good hero-killer) he should be, but I think if he loses Dark Will he should be able to compete much more against heroes in normal mode.
Gil-galad, Elendil and unknown amounts of support from Elrond, Isildur and Cirdan are not exactly the same as Haldir.
I will maybe make some suggestions in the future, I had a half-finished concept lying around somewhere.
Signed,
The Only True Witchking
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